On 25th May 2018 the EU’s General Data Protection Regulation (GDPR), the successor to the Data Protection Act, became enforceable across Europe including the UK. Happier Eating is the online presence of The Nutrition Partnership Limited; Happier Eating holds some information about you. This document tells you how that information is used, who we may share that information with, and how we keep it secure.
This document does not provide exhaustive detail however, we are happy to provide any further information or explanation that may be required. Any requests for this should be sent to firstname.lastname@example.org
What we do:
Happier Eating is the online identity and presence of The Nutrition Partnership Limited and provides nutrition management and hypnotherapy services to clients to improve their health through diet and lifestyle adjustments. We focus on preventative healthcare, the amelioration of physical and mental wellbeing and chronic health conditions.
Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, we aim to understand the underlying causes of health issues which we will seek to manage through personalized dietary therapy, nutraceutical recommendations (supplements) and lifestyle advice.
Through hypnotherapy consultations, we aim to help you adjust any behaviours or beliefs that may be having an unhelpful influence on your health by the provision of personalized hypnotherapy sessions.
We also offer workshops and presentations to groups in private or corporate settings. These sessions are designed to offer education and build awareness of factors influencing diet and lifestyle.
How we obtain your data:
Information provided by you
You provide us with personal data through:
• Completing a pre-consultation questionnaire
• Signing a Terms of Engagement form
• Our discussions during your consultations
• Through emails, over the telephone, online platforms such as Zoom, and by post
• Payments made using credit cards or online payment services
This may include the following information:
• Basic details such as name, address, contact information and next of kin
• Details of any contact we have with you such as referrals and appointment requests
• Health information, including but not limited to health history, lifestyle, diet, medical test results, medication regimes, biochemical test results, clinic notes, health improvement plans
• GP contact information
We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
Following completion of your healthcare we retain your personal data for the period defined by our professional associations and registrant body, CNHC. This enables us to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration.
Information provided by others
We may obtain sensitive medical information in the form of test results from biochemical testing companies. We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
We may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to co-ordinate your healthcare with that offered by other providers which means that the healthcare provided by us may be less effective.
How we use your personal data:
We act as a data controller for use of your personal data to provide direct healthcare. We also act as a controller and processor in regard to the processing of your data form third parties such as testing companies and other healthcare providers. We act as a data controller and processor in regard to the processing of credit card and online payments.
We undertake at all times to protect your personal data, including any health and contact details, in a manner consistent with our duty of professional confidence and the requirements of the GDPR concerning data protection. We will also take reasonable security measures to protect your personal data storage.
We may use your personal data where there is an over-riding public interest in using the information, e.g. in order to safeguard an individual, or to prevent a serious crime, or where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as e-newsletters but this would be subject to you providing your express consent.
Sharing your information with other organisations:
We will keep the information we have about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
• Our registrant body, CNHC, and our professional association, GHSC, for the processing of any complaint made by you
• Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential
• Anyone to whom we may transfer our rights and duties under any agreement we have with you
• Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. CNHC) if we have a duty to do so or if the law allows us to do so
We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. We will not include any sensitive information.
We will seek your express consent before sharing your information with your GP or other healthcare providers. However, if we believe that your life is in danger then we may pass on your information to an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.
We may share your case history in anonymised form with our peers for the purposes of professional education and development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines, or online professional sites. We will seek your explicit consent before processing your data in this way.
What are your rights?
Every individual has the right to see, amend, delete or have a copy of, data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want access to your data you must make a subject access request in writing to email@example.com Under special circumstances, some information may be withheld. We shall respond within 14 days form the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:
• Sources form where we acquired the information
• The purposes of processing the information
• Persons or entities with whom we are sharing the information
You have the right, subject to exemptions, to ask to:
• Have your information deleted
• Have your information corrected or updated where it is no longer accurate
• Ask us to stop processing information about you where we are not required to do so by law or in accordance with the GHSC or CNHC guidelines
• Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, without hindrance from us
• Object at any time to the processing of personal data concerning you
We do not carry out any automated processing which may lead to an automated decision based on your personal data.
If you would like to invoke any of the above rights then please contact Sabra Ralph (Data Controller) by emailing firstname.lastname@example.org
The safeguards in place to ensure your identifying data is secure:
We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your data will be used, and allow you to decide if and how your information can be shared.
We also ensure that the information we hold is kept in secure locations, restrict access to information to authorized personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorized users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data could or does identify a person are processed.
The Nutrition Partnership Limited is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of this registration is available through the ICO website (search by business name).
How long we hold confidential information:
All records held by The Nutrition Partnership Limited wil be kept for the duration specified by guidance from our professional association, GHSC/GHR.
Website technical details:
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We aim to use secure forms where appropriate.
If you have a complain regarding use of your personal data then please contact us by writing to Sabra Ralph at email@example.com and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.
All content provided on this website, including downloadable resources, is for informational purposes only. Sabra Ralph, happiereating, or The Nutrition Partnership Limited make no representations as to the accuracy or completeness of any information on this site or found by following any link on this site. Neither Sabra Ralph, happiereating, nor The Nutrition Partnership Limited will be liable for any errors or omissions in this information nor for the availability of this information. Sabra Ralph, happier eating, or The Nutrition Partnership Limited will not be liable for any losses, injuries, or damages from the display or use of this information. We are not responsible for the republishing of the content found on this site on other websites or media without our permission.